AML and KYC Policy

INTRODUCTION  

Astral HodlingOÜ, the creator of Lean Community (hereinafter – “Lean Community”) and the the issuer of Lean Management Token (LEAN). Anti-Money Laundering and Know Your Customer Policy (hereinafter – “AML and KYC Policy”) is designated to prevent and  mitigate possible risks of Lean Community being involved in any kind of illegal activity. 

Both international and local regulations require Lean Community to implement effective  internal procedures and mechanisms to prevent money laundering, terrorist financing,  drug and human trafficking, proliferation of weapons of mass destruction, corruption and  bribery and to take action in case of any form of suspicious activity from its Users. 

This AML and KYC Policy applies to both natural and legal persons. Legal entities joining  the Lean Community ICO, which is defined as making a Lean Community purchase in a  specific method stated in the clause 4 of this AML and KYC Policy will receive purchased  tokens to their ERC-20 address after required AML and KYC procedures that include  providing specific documents. 

AML and KYC Policy covers the following matters:  

  1. Verification procedures. 

1.1. Basis 

1.2. Identity verification 

1.3. Anti-money laundering procedure 

1.4. Authenticity verification 

1.5. Right to report 

1.6. Continuous basis of information verification 

1.7. Transaction proceed refusal 

1.8. Payment cancellation 

  1. Compliance Officer. 

2.1. Definition 

2.2. Duties 

2.3. Law enforcement

  1. Monitoring Transactions. 

3.1. Data analysis 

3.2. Suspicious transactions reporting 

  1. Payment methods 

4.1. Coinbase, Metamask, payment cards 

4.2. Payment cards usage control 

4.3. Coinbase and Metamask transfer control 

4.4. Address analysis 

4.5. Liability 

4.6. Due diligence 

  1. Risk Assessment. 
  2. AML and KYC Policy 

6.1. Acceptance 

6.2. Privacy Policy 

1. Verification procedures.  

1.1. Basis  

One of the international standards for the prevention of illegal activities is Know Your  Customer (“KYC”). According to the KYC, Lean Community establishes its own verification  procedures within the framework of anti-money laundering standards and Know Your  Customer. 

1.2. Identity verification  

Lean Community’s identity verification procedure requires the User to provide reliable  independent sources of documents, data or information (e.g. ID card, international  passport, bank statement, utility bills) every time the User is requested to provide certain  information. For AML and KYC Policy purposes, Lean Community hereby reserves the right to  collect User information.

1.3. Anti-money laundering procedure  

Lean Community’s anti-money laundering procedure requires the User to provide information  about the source of the funds the User uses to purchase Lean ManagementTokens every time  the User is requested to provide certain information. Lean Community is not responsible for  any errors or omissions in the information provided by the User. 

1.4. Authenticity verification  

Lean Community shall take steps to verify the authenticity of documents and information  provided by Users, use all legal methods to double-check identification information and  hereby reserves the right to investigate the actions of certain Users that have been found  risky or suspicious.  

1.5. Right to report  

We may therefore report our suspicions regarding any activity of the users to local  regulators, enforcement bodies and other compliance bodies. Those kind of actions  have a goal of ensuring that the capital being used on our platform has a legitimate  origin and create a safeguard in case of individuals or groups wanting to allocate  their money from illegal activities on our platform. 

1.6. Continuous basis of information verification  

Lean Community hereby reserves the right to verify the User’s identity on a continuous  basis, especially when the verification information has been changed or the User’s  activity has been deemed suspicious, even if they have already undergone identity  verification. User verification information shall be collected, stored, transferred and  protected strictly in accordance with Lean Community’s Data Protection Policy and the  relevant rules. Following the verification of User’s identity, Lean Community disclaims  potential legal liability in situations where its Services are used for illegal activities. 

1.7. Transaction proceed refusal  

Lean Community may refuse to proceed the transaction of transferring the purchased  tokens to the User if the User refuses to provide any demanded information. Lean Community may refuse to issue tokens to the User if:  

  1. The User does not provide any demanded information to Lean Community and  enables to complete any diligence procedures on the User; 
  2. The User have been previously identified as engaged in suspicious activity; c. The User is the citizen of a country considered to be exposed to a high risk of  money laundering or financing terrorism; 
  3. The User is listed on a sanctions list in any of the jurisdictions to which  Lean Community may transfer purchased tokens, or Lean Community otherwise identifies the User as exposed to a high risk of money laundering or financing  terrorism. 

1.8. Payment cancellation.  

The User cannot cancel a request to purchase the tokens. Lean Community may cancel  the User’s purchase of the tokens if it is impossible to verify User’s identity or  conduct any other procedures that Lean Community is required to conduct. Student  Coin may not refund User any amount until the User has provided any demanded  information required by law. 

2. Compliance Officer  

2.1 Definition  

The Compliance Officer is the person, duly authorized by Lean Community, whose duty  is to ensure the effective implementation and enforcement of the AML and KYC  Policy. 

2.2 Duties  

It is the Compliance Officer’s responsibility to supervise all aspects of Student  Coin’s anti-money laundering and counter-terrorist financing, including but not  limited to: 

  1. Collecting User’s identification information; 
  2. Establishing and updating internal policies and procedures for the  completion,review, submission and retention of all reports and records  required under theapplicable laws and regulations; 
  3. Monitoring transactions and investigating any significant deviationsfrom  normal activity; 
  4. Implementing a record management system for appropriate storageand  retrieval of documents, files, forms and logs; 
  5. Updating risk assessment regularly; 
  6. Providing law enforcement with information as required under theapplicable laws and regulations. 

2.3 Law enforcement  

The Compliance Officer is entitled to interact with law enforcement, which are  involved in prevention of money laundering, terrorist financing and other illegal  activity. 

2.4 Contact with the clients and authorities 

The Compliance Officer is obliged to communicate effectively with the clients and  authorities having any complaints or questions that are being addressed to him  regarding the Lean Community AML and KYC Policy as also its implementation in order  to ensure the transparency and credibility of the platform. The address to contact  the Compliance Officer is [email protected] Any kind of correspondence sent to the Compliance Officer will be addressed by him within the time frame of 5  working days. 

3. Monitoring transactions  

3.1 Data analysis  

User verification is carried out not only by checking their identity, but also by  analyzing transaction models. Lean Community therefore relies on data analysis as a  tool for assessing risk and identifying suspicions. Lean Community carries out many  regulatory compliance tasks, including data collection, filtering and record keeping. 

3.2 Suspicious transactions reporting  

With regard to the AML and KYC Policy, Lean Community will monitor all transactions,  and it reserves the right to ensure that transactions of suspicious nature are  reported to the proper law enforcement through the Compliance Officer and request  the User to provide any additional information and documents in case of suspicious  transactions. Compliance Officer will monitor User’s transactions on a day-to-day  basis in order to define whether such transactions are to be reported and treated  as suspicious or are to be treated as bona fide. 

4. Payment methods  

4.1 Coinbase Commerce, Metamask, payment card  

The User may purchase Lean ManagementTokens by linking the Metamask wallet and  managing the Ethereum deposit, transferring any cryptocurrency by Coinbase  Commerce, or by card or wire transfer. To carry out a transaction in a chosen way,  the User must follow the relevant instructions on the Lean Community site.

4.2 Payment cards usage control  

Lean Community may refuse to complete or block, cancel or reverse a transaction of  the Lean ManagementToken purchase made with payment cards usage if the User is  suspected of money laundering, terrorist financing, fraud, any other financial crime,  or any other illegal action. Lean Community is under no obligation to disclose the details  of its credit card risk management and security procedures to the User. 

4.3 Coinbase Commerce and Metamask transfer control  

Lean Community may refuse to complete or block, cancel or reverse a transaction of  the Lean Management Token purchase made with Coinbase (Coinbase, Inc. 100 Pine  Street, Suite 1250, San Francisco, CA 94111) or Metamask (MetaMask ℅  ConsenSys, 49 Bogart Street, Brooklyn NY 11206) usage if the User is suspected  of money laundering, terrorist financing, fraud, any other financial crime, or any  other illegal action. 

4.4 Address analysis  

Lean Community may analyze the cryptocurrency addresses against common blacklists  and known security discrepancies, to ensure that the funds do not come from illicit  sources, and there are no signs of money laundering (location, layers, integration),  either manually or using a third-party service. 

4.5 Liability  

Lean Community has no control over, or liability for, the delivery, quality, safety and  legality or any other aspect of any goods or services received or purchased from  Coinbase or Metamask. 

5. Risk assessment  

Lean Community, in accordance with international requirements takes a risk-based  approach to combating money laundering and the financing of the terrorism. By  applying a risk-based approach, Lean Community can ensure that measures to prevent  or mitigate money laundering and terrorist financing are proportionate with the  identified risks. This makes it possible for resources to be allocated in the most  efficient way. The principle is to allocate resources corresponding to priorities so  that the highest risks are given the closest attention. 

6. AML and KYC Policy  

6.1 Acceptance  

By joining the Lean Community ICO, which is defined as making a Lean ManagementToken  purchase in a specific method stated in the clause 4 of this AML and KYC Policy,  the User accepts the terms of this AML and KYC Policy and hereby agrees to have  read, understood and accepted the Terms of Use and Data Protection Policy  available at: https://leancommunity.org/privacy-policy/In addition, when using  certain services, the User may be subject to additional agreements applicable to  such services. The User must stop using the services and the website if they do not  agree with the AML and KYC Policy and the Terms of Use and Data Protection Policy. 

6.2 Privacy policy  

User’s identification information will be collected, stored, shared and protected  strictly in accordance with the Lean Community’s Privacy Policy and related regulations.